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Oil and Gas Program Audit: Enforcement and Compliance Issues in St. Tammany

This audit highlights the ineffective enforcement and compliance practices of the Office of Conservation in St. Tammany regarding routine inspections, rule enforcement, financial penalties, site closure, and identification of inactive sites. The audit also compares state regulations to industry standards set by the American Petroleum Institute.

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Oil and Gas Program Audit: Enforcement and Compliance Issues in St. Tammany

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  1. Performance Audit (May 2014) Office of Conservation, DNR Oil and Gas Program • Concluded (among others): • Does not perform appropriate routine inspections • Does not adequately enforce its rules • Rarely issues financial penalties • Does not deter future or ongoing violations • Does not have adequate bonding to close sites when operators walk away • Does not effectively identify inactive sites

  2. STRONGER Audit (2010-2011) • State Review of Oil and Gas Environmental Regulations (STRONGER) • Concluded (among others): • Surface casing not protective of groundwater (depth) • Casing cement standards insufficient for anticipated pressures • Spill prevention programs inadequate (180 days to prepare / 1 year to implement) • Staff insufficiently trained for fracturing

  3. Regulations compared to industry standards • American Petroleum Institute (API) standards for hydraulic fracturing and associated waste management • Hydraulic Fracturing Operations – Well Construction and Integrity Guidelines, HF1 (2009) • Water Management Associated with Hydraulic Fracturing, HF2 (2010) • Practices for Mitigating Surface Impacts Associated with Hydraulic Fracturing, HF3 (2011)

  4. API Comparison • Should avoid wetlands • Formation pressure testing • Depth of surface casing • Mechanical integrity tests such as CBL, temperature logs on all casings, etc. • Locate and test public, private water wells, lakes, etc. • Baseline and post fracture monitoring • Tracer tagging to confirm extent

  5. Sole Source Aquifer

  6. Water Withdrawals, St. Tammany

  7. Generalized Cross Section

  8. Other Sources

  9. Chemical Use • 2,500 fracturing products • 750 chemicals • 29 carcinogens, SDWA, and / or HAPs • Harmful: no smell, no taste, no visual

  10. Water Use in St. Tammany • 10-mile radius from approximate middle of lease area. • Over 4,700 water wells use for private homes (4,476), public supply (204), irrigation (80), Industrial (80) • Depths ranged from 15 to 2,350 feet • Assortment of sand aquifers

  11. Leases in St. Tammany

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